Editor’s Note: The public is encouraged to provide comments on each of the following posts by either using the “comment” section below each post or providing a new post by using the mechanism to the right of this post.

CRE Brazil has also published numerous articles on marine sound and related issues and is invovled in a multinational effort to foster international harmonization on marine sound issues.

The public policy discussions surrounding sesimic operations in the Gulf of Mexico, an activity necessary for energy independance, will be managed by BOEM and NWFS; the most influentital stakeholder input to these two ogranizations will be delivered by the following organizations all of which have historically been deeply involved in the issue.

The consideration and ultimate acceptance of the material on an IPD by federal regulators and their regulatory overseers depends in large part on the recognized regulatory expertise and federal credentials of the managers of the organization which hosts the IPD.

American Petroleum Insititute

:”While we continue to have concerns over the manner by which some of these new regulatory requirements were developed and implemented (e.g., Notices to Lessees and interim final rules used in lieu of formal notice-and-comment rulemaking), we do believe industry is operating in compliance with the new requirements.”. See API 2

“The opportunities presented to FWS are many and varied, but the key to their realization is to provide regulatory certainty to participating property owners, including protection from incidental take liability.” See API_ANOPR[1]

Center for Regulatory Effectiveness

“NMFS is in the process of revising the incidental take rules for oil and gas exploration in the Gulf of Mexico. CRE alerts NMFS to the statutory requirement that all such actions be in compliance with the Data Quality Act..” See this and this.

Consortium of Energy Associations

“The Associations support the BOEMRE, on behalf of industry, petitioning the NMFS for incidental takes authorization of marine mammals under the Marine Mammal Protection Act (MMPA).” See Consortium BOEM

International Association of Geophysical Contractors

“In addition, the commet letter emphasized that geophysical surveys do not result in adverse impacts to the populations of marine mammals, that existing scientific information and not speculation should be used when analyzing potential environmental effects of seisimic surveys…” See IAGC ..

Marine Mammal Commission

” The Marine Mammal Commissin recommends. that, in the proposed rule, the National Marine Fisheries Service—include a requirement in the proposed rule that passive acoustic monitoring be used to collect data on the occurrence, abundance, distribution, and movement of marine mammals.” Marine Mammal Commission NMFS

Natural Resource Defense Council

“Increasingly, the available science indicates that seismic airguns disrupt baleen whale behavior and impair their communication on a vast scale; that they harm a diverse range of other marine mammals in multiple ways; and that they significantly impact fish and fisheries, with unknown but potentially substantial effects on both coastal communities and marine mammal populations.” See Natural Resources Defense Council Also see public comments in the comment section below. (CRE will be responding to these comments in a subsequent post}.

Ocean Conservation Research

“Furthermore, while we may be arguable that “Level B” behavioral adaptations to proposed activities would be disruptive but recoverable, there is absolutely no justification for biological damage indicated in a “Level A” harassment. Even short term “recoverable” assaults such as temporary threshold shift (TTS) are barbaric.” See Ocean Conservation Research

Sierra Club

“Sierra Club believes there is an insufficient basis for NMFS to find that the proposed takings would have only a negligible impact on the affected species and stocks of marine mammals, in particular the stock of sperm whales likely to be affected by these activities in the Gulf of Mexico and protected by listing under the Endangered Species Act”. (CRE will be responding to these comments in a subsequent post}.

“Increasingly, the available science indicates that seismic airguns disrupt baleen whale behavior and impair their communication on a vast scale; that they harm a diverse range of other marine mammals in multiple ways; and that they significantly impact fish and fisheries, with unknown but potentially substantial effects on both coastal communities and marine mammal populations.”

CRE Response

“ Recent assessments by BOEM and others show that seismic and other oil and gas G&G have not caused any harm in the Gulf of Mexico (“GOM”) under current, long standing regulation. There is no need or basis for seismic regulation which is more stringent than that imposed by BOEM’s JOINT NTL No. 2012-G02, Notice to Lessees and Operators of Federal Oil, Gas, and Sulphur Leases in the OCS, Gulf of Mexico Region, Implementation of Seismic Survey Mitigation Measures and Protected Species Observer Program, available online at http://www.bsee.gov/Regulations-and-Guidance/Notices-to-Lessees/2012/2012-JOINT-G02-pdf.aspx . Significantly more stringent seismic regulation would be inconsistent with several recent BOEM Environmental Impact Statements (“EIS”).”